In a letter dated April 8, 2011 from Robert Plaze, Associate
Director of the SEC, to the President of the North American
Securities Administrators Association, Mr. Plaze confirmed that the
SEC is "considering" an extension of certain deadlines
imposed by the Dodd-Frank Act, and associated SEC rulemaking, to
the first quarter of 2012. See the attached link for the actual
letter on the SEC website. http://sec.gov/rules/proposed/2010/ia-3110-letter-to-nasaa.pdf.
Mr. Plaze stated in the letter that the SEC expects the final
rules regarding the venture capital and private fund adviser
exemptions will be published by the July 21 deadline. The letter
also states that the SEC expects that they will
"consider" extending, to the first quarter of 2012, the
date by which advisers must register and come into compliance with
all rules applicable to registered advisers.
The letter further states that it is expected that the SEC will
consider extending to the first quarter of 2012 the date by which
midsize advisers (certain advisers having between $25 million and
$100 million in assets under management) would have to transition
to state registration.
We will keep clients and friends of the firm updated regarding any extensions actually granted by the SEC.
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